Anti Fraud Policy Paper

ANTI-FRAUD POLICY

Background

The risks from fraud can have a major impact on P&W Inc. These acts of fraud are a result of dishonesty, misconduct, and deception. They often come with a cost to our company. The impact on our company is often much greater than the original fraudulent act and could result in some of the items listed below:

• Financial loss

• Loss of employees and/or customers

• Lawsuits

• Loss of business relationships

The management staff at P&W Inc. takes pride in the relationships we have with our staff, our customers, and other businesses. We are committed to a zero-tolerance policy when it comes to fraud in order to protect our company and help maintain our positive relationships with everyone involved in our business.

Any suspected fraudulent activity will be investigated according to the rules and actions set out within this policy regardless of the relationship with our company.

Policy

The management staff at P&W Inc. is trained to be able to identify fraudulent activity. Every member of management is familiar with the different forms of fraud and knows many different signs of fraudulent activity to be mindful of. Unfortunately, our management staff cannot be everywhere all the time. We must rely on our employees to be the eyes and ears of our company because you are valuable assets to our company.

It is the responsibility of every person on the management staff to promptly report suspicions of fraud they have found but also reports that have been brought to them by other people. Those reports will be turned over to our dedicated fraud department within 24 hours to be investigated.

Actions Constituting Fraud

Fraud is defined, but not limited to, the following:

• Any dishonest or deceitful act for personal or financial

feels that everyone is a valuable asset to the company. Everyone working for this company, as well as everyone doing business with this company, is at risk for huge losses if fraud is detected. That is why, here at P&W Inc., we expect for everyone working for us (employees, supervisors, managers, etc.) to report any kind of suspicious activity to your direct manager or supervisor. Reports that are made will remain anonymous. If you are not comfortable reporting the activity to your manager or supervisor, you may call the fraud prevention hotline at 1-800-PW-FRAUD. Your report will be taken over the phone and will also remain anonymous.

Once the report is given to your manager, supervisor, or the hotline, they will then immediately take those reports to a specialized fraud investigation team. It is important you understand the supervisors and managers will not be doing the investigations into the fraud claims. These will be handled by a specialized team that does not work directly with employees and other people doing business with the company. This is so the investigation will be completely unbiased and based only on the facts of the case.

Investigative